EMERGENCY PETITION UNDER RULE 20 FOR EXTRAORDINARY WRIT OF MANDAMUS IN THE SUPREME COURT OF THE UNITED STATES In Re: CORECO JA’QAN PEARSON, VIKKI TOWNSEND CONSIGLIO, GLORIA KAY GODWIN, JAMES KENNETH CARROLL, JASON M SHEPHERD on behalf of the COBB COUNTY REPUBLICAN PARTY, and BRIAN JAY VAN GUNDY Petitioners, STATE OF GEORGIA, BRIAN KEMP, in his official capacity as Governor of Georgia, BRAD RAFFENSPERGER, in his official capacity as Secretary of State and Chair of the Georgia State Election Board, DAVID J. WORLEY, in his official capacity as a member of the Georgia State Election Board, REBECCA N. SULLIVAN, in her official capacity as a member of the Georgia State Election Board, MATTHEW MASHBURN, in his official capacity as a member of the Georgia State Election Board, and ANH LE, in her official capacity as a member of the Georgia State Election Board, Respondents

 

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CASE NO. 

IN THE SUPREME COURT OF THE UNITED STATES 

In Re: 

CORECO JA’QAN PEARSON, VIKKI TOWNSEND CONSIGLIO, GLORIA KAY GODWIN, JAMES KENNETH CARROLL, JASON M SHEPHERD on behalf of the COBB COUNTY REPUBLICAN PARTY, and BRIAN JAY VAN GUNDY Petitioners, 

STATE OF GEORGIA, BRIAN KEMP, in his official capacity as Governor of Georgia, BRAD RAFFENSPERGER, in his official capacity as Secretary of State and Chair of the Georgia State Election Board, DAVID J. WORLEY, in his official capacity as a member of the Georgia State Election Board, REBECCA N. SULLIVAN, in her official capacity as a member of the Georgia State Election Board, MATTHEW MASHBURN, in his official capacity as a member of the Georgia State Election Board, and ANH LE, in her official capacity as a member of the Georgia State Election Board, Respondents 

EMERGENCY PETITION UNDER RULE 20 FOR EXTRAORDINARY WRIT OF MANDAMUS 

SIDNEY POWELL 

Counsel of Record 

Texas Bar No. 16209700 

Sidney Powell, P.C. 

2911 Turtle Creek Blvd., Suite 300 

Dallas, Texas 75219 

(517) 763-7499 

sidney@federalappeals.com 

Of Counsel JULIA Z. HALLER 

BRANDON JOHNSON 

EMILY P. NEWMAN 

 /s/ Howard Kleinhendler 

HOWARD KLEINHENDLER 

New York Bar No. 2657120 

Howard Kleinhendler Esquire 

369 Lexington Avenue, 12th Floor 

New York, New York 10017 

(917) 793-1188 

howard@kleinhendler.com 

HARRY W. MACDOUGALD 

Georgia Bar No. 463076 

Caldwell, Propst & DeLoach, LLP 

Two Ravinia Drive, Ste 1600 

Atlanta, Georgia 30346 

(404) 843-1956 

hmacdougald@cpdlawyers.com 

L. LIN WOOD 

Georgia Bar No. 774588 

L. LIN WOOD, P.C. 

P.O. Box 52584 

Atlanta, GA 30305-0584 

(404) 891-1402 

QUESTIONS PRESENTED 

REASONS IN SUPPORT OF GRANTING EMERGENCY APPLICATION FOR EXTRAORDINARY WRIT OF INJUNCTION 

ARGUMENT 

I. THE DISTRICT COURT ERRED WHEN IT DISMISSED THE COMPLAINT AND TRO MOTION. 

A. Presidential Electors have standing to challenge the outcome of a presidential election for fraud and illegality that cause the defeat of their candidate. 

B. The Petitioners’ Claims Are Not Barred by Laches. 

C. Federal courts have and should exercise jurisdiction under 42 U.S.C. § 1983 over claims by Presidential Elector candidates that the election was stolen from them by fraud and illegality under color law in violation of their constitutional rights. D. The District Court erred to the extent it dismissed the complaint as moot. 

II. RESPONDENTS VIOLATED THE U.S. CONSTITUTION AND GEORGIA STATE LAW. 

A. Respondents Violated the Electors Clause by Modifying the Georgia Election Code Through Non-Legislative Action. 

B. Respondents Knowingly Enabled Election Fraud by Election Workers, Dominion, Democratic Operatives, Unknown Third Parties, and Potentially by Hostile Foreign Actors. 

C. Petitioners Submitted Expert Witness Testimony Establishing Wide-Spread Voting Fraud That Changed The Outcome of the Election. 

D. Respondents’ Actions Satisfy the Requirements for a Constitutional Election Fraud Claim under 42 U.S.C. § 1983 That Can Be Remedied by This Court. 

  CONCLUSION 

WHEREFORE, the Petitioners respectfully request this Honorable Court grant this Emergency Petition Under Rule 20 For Extraordinary Writ Of Mandamus To Vacate the December 7 Judgment of the United States District Court for the Northern District of Georgia. Petitioners seek an emergency order instructing Respondents to de-certify the results of the General Election for the Office of President, and prohibiting Respondents from empaneling the Biden slate of electors to cast their votes in the Electoral College 

Petitioners seek an emergency order prohibiting Respondents from including in any certified results from the General Election the tabulation of absentee and mailing ballots which do not comply with the Georgia Election Code. 

Petitioners further request that this Court direct the District Court to order production of all registration data, ballots, envelopes, etc. required to be maintained by Georgia state and federal law, to refrain from wiping or otherwise tampering with the data on all voting machines used in the November 2020 election, and to produce one such machine from each Georgia county for forensic examination by Petitioners’ experts. 

Date: December 11, 2020 

J U D G M E N T 

JAMES N. HATTEN 

CLERK OF COURT 

December 7, 2020 

Transcript of Motions Hearing Before The Honorable Timothy C. Batten, Sr. United States District Judge